Tednologies, Inc. - Comment

Division of Dockets Management (HFA–305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061 Rockville, MD. 12/3/2009 Docket No. FDA–2009–N–0523 Comments intended for use in the Dec. 10 public meeting. The Food and Drug Administration (FDA), in collaboration with the United States Department of Agriculture, Food Safety and Inspection Service (FSIS), announced a public meeting regarding product tracing systems for food intended for humans on Dec. 10. This is a written response to intended to offer suggestion to this agenda by Tednologies, Inc. of Anchorage, Alaska. Federal food safety agencies need to increase the speed and accuracy of trace back investigations and trace forward operations to ensure quality, safety, freshness and lack of contaminants exposed to food intended for human consumption. Tednologies, Inc. has since its inception been a leader in research and development in the shipping of Alaska fresh seafood and agricultural products as well as other perishable food items to provide traceability and quality delivery of food products to Alaskans and Lower-48 retail and restaurant outlets. In response we feel that the core elements of a tracing system must include time and temperature and any handling information. To be more specific we believe that with the proper shipping containers and Radio Frequency Identification (RFID) that traceability will identify when a food product has been introduced to contamination. In our case the TEDSBOX (that stands for Tracking Environmental Deviation System BOX) is currently used for distribution of heat and cold sensitive food products that do not need human intervention to open or close the container during shipment . On board batteries operate the units for up to five days from the date of shipping. If for example the TEDSBOX is opened (cold chain broken) during shipping an RFID tag shows the exact amount of time, when and what the contents were exposed to (temperatures) during the s